Customer alleged misrepresentation of distributions and liquidity features associated with a REIT Investment.

$30,000.00

$14,000.00

INVESTMENTS WERE SUITABLE AND APPROPRIATE AT THE TIME THEY WERE MADE AND REPRESENTED IN ACCORDANCE WITH ALL APPLICABLE POLICIES AND PROCEDURES. CLIENTS SIGNED ALL REQUIRED DOCUMENTATION AND ADDITIONAL LETTERS OF INVESTMENT UNDERSTANDING. ALSO, CLIENT HAD PRIOR EXPERIENCE WITH SIMILAR INVESTMENTS. WE BELIEVE THAT THE ALLEGATIONS ARE WITHOUT MERIT AND REPRESENTATIVE DENIES ALL ALLEGATIONS. HOWEVER, TO AVOID FURTHER TIME AND EXPENSE AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS SET FORTH IN THE CLAIM, THE PARTIES SETTLED. REGISTRANT DID NOT CONTRIBUTE TO SETTLEMENT.

ARBITRATION STATEMENT OF CLAIM ALLEGED BREACH OF FIDUCAIRY DUTY, BREACH OF CONTRACT; MISPREPRESENTATION IN CONNECTION WITH A REIT OFFERING AND TENANT IN COMMON OFFERING PURCHASED IN 2006-2007.

$300,000.00

$40,000.00

INVESTMENTS WERE SUITABLE AND REPRESENTED IN ACCORDANCE WITH BOTH FIRMS' POLICIES AND PROCEDURES. CLIENT SIGNED ALL REQUIRED DOCUMENTATION INCLUDING ELLIGIBILITY AND RISK STATEMENTS. REPRESENTATIVE DENIES ALL ALLEGATIONS AND WILL DEFEND HIS POSITION. TO AVOID FURTHER COSTS AND RESOURCES ASSOCIATED WITH A DISPUTE, WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS CONTAINED IN THE CLAIM, THE PARTIES SETTLED ON JANUARY 17, 2012. REGISTRANT DID NOT CONTRIBUTE TO THE SETTLEMENT. *NOTE- 2 FIRMS WERE INVOLVED IN DISPUTE AND SETTLED SEPARATELY, IFG IN THE AMOUNT OF $40,000 AND PRO-EQUITIES IN THE AMOUNT OF $65,000.

ARBITRATION STATEMENT OF CLAIM ALLEGES MISREPRESENTATION, OMMISSIONS, FRAUD, BREACH OF FIDUCIARY DUTIES AND VIOLATIONS OF CA CORPORATIONS CODE IN CONNECTION WITH 3 DPPS AND 1 VARIABLE ANNUITY PURCHASED BETWEEN 2001 AND 2007.

$665,000.00

$160,000.00

CLIENTS WERE AT THE TIME OF PURCHASE AND REMAIN EXPERIENCED AND SOPHISTICATED INVESTORS. INVESTMENTS WERE SUITABLE AND REPRESENTED IN ACCORDANCE WITH FIRMS POLICIES AND PROCEDURES. CLIENTS SIGNED ALL REQUIRED DOCUMENTATION AND ADDITIONAL LETTERS OF INVESTMENT UNDERSTANDING. CLAIM IS WITHOUT MERIT, REPRESENTATIVE DENIES ALL ALLEGATIONS AND WILL DEFEND HIS POSITION. TO AVOID FURTHER TIME AND EXPENSE AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS SET FORTH IN THE CLAIM, THE PARTIES SETTLED. REGISTRANT DID NOT CONTRIBUTE TO SETTLEMENT.

CLAIM ALLEGES BREACH OF FIDUCIARY DUTY; NEGLIGENCE; NEGLIGENT SUPERVISION; MISREPRESENTATION; FRAUD; VIOLATION OF CA CORP CODE IN CONNECTION WITH DPPS & VA PURCHASES IN 2007-2008.

$200,000.00

$40,000.00

WITHOUT ADMITTING OR DENYING ANY WRONGDOING BY THE REGISTRANT OR BROKER-DEALER, THE PARTIES SETTLED IN ORDER TO AVOID FURTHER COSTS. REGISTRANT DID NOT CONTRIBUTE TO SETTLEMENT.

CLAIM ALLEGES UNSUITABILITY, NEGLIGENCE, BREACH OF FIDUCIARY DUTY, BREACH OF CONTRACT IN RELATION TO DPP'S.

$500,000.00

$89,000.00

WITHOUT ADMITTING OR DENYING ANY WRONGDOING BY THE REGISTRANT OR BROKER-DEALER, THE PARTIES SETTLED IN ORDER TO AVOID FURTHER COSTS. REGISTRANT DID NOT CONTRIBUTE TO SETTLEMENT.